On May 1, 2017, TE/GE formed the CP&C office to streamline and consolidate processes that identify, research, select and monitor inventory using data analytics.

The TE/GE Compliance Governance Board (the "Board" ):

The compliance strategy process replaced the compliance initiative process in TE/GE.

The Board’s charter lists the following TE/GE officials as voting members of the Board:

The Board’s non-voting members include:

The Board Chair is responsible for presiding over meetings and performing administrative activities (e.g., preparing agendas and meeting minutes).

CP&C’s responsibilities include, but are not limited to, the following tasks:

Classification: The group within the Classification & Case Assignment (C&CA) function in CP&C that is responsible for classifying cases. See IRM 4.70.6, Classification and Case Assignment Procedures, for more information on Classification.

Classifier: A person in C&CA responsible for classifying compliance activity cases.

Compliance Governance Board (the "Board" ): See IRM 4.70.5.1.2, above.

Compliance Activity: The development of issue submissions into compliance strategies and data driven approaches.

Compliance Strategy: An issue developed through the compliance strategy process and approved by the Board.

Data Driven Approach: A recurring compliance activity approved by the Board that may be the result of the compliance strategy process or another research effort. Both compliance strategies and data driven approaches allow TE/GE to identify, prioritize, and allocate resources to TE/GE compliance activities.

Exam Director: The Examination Director in EO or EP and the Director, Government Entities.

Issue Development Team (ID Team): The team of experts brought together by the IID analyst to participate in the compliance strategy process. This may include employees from the functions and from Knowledge Management (KM), Communications and Liaison or Leadership Education and Delivery Services.

Issue Identification and Special Review (II&SR): A function within CP&C that is responsible for issue identification, research and special review.

IID Analyst: The analysts in II&SR, Issue Identification (IID) group that review submissions, develop proposals, and make recommendations of compliance activities to the Board.

IID Manager: The frontline manager of the IID group.

Planning and Monitoring (P&M) Coordinator (PMC): P&M personnel assigned to one or more compliance strategies or data driven activities—from proposal development through the presentation of results and recommendations.

Research: A group within II&SR that is staffed with analysts, economists, and statisticians who provide analytical support throughout compliance activity development and respond to ad hoc data requests.

Research Manager: The frontline manager of the research group.

Stocking Report: A report prepared by the VSM and sent to C&CA that requests the amount of work to be added to the virtual shelf (work type, grade)

TE/GE Issue Submission Portal (the "Portal" ): A SharePoint-based site where employees can submit ideas about an area of non-compliance. The compliance strategy process determines if the submission is viable and could be developed into a compliance strategy or data driven approach.

Virtual Shelf Monitor (VSM): P&M employee who requests establishment of compliance activity cases in anticipation of functional casework needs.

Work Plan Analyst (WPA): P&M employees designated to provide support on developing submissions and Board approved compliance strategies and data driven approach activities with consideration of the effect on the annual functional workplans.

Acronyms:

The IRS has the following main objectives surrounding workload selection:

CP&C was created to address concerns regarding the separation of classification and workload selection from the exam functions.

Program Reports: Within CP&C, electronic systems are used to house documents related to the compliance strategy process. Access to the systems (e.g., AIMS, RCCMS, Portal) is restricted.

TE/GE ensures that adequate and effective controls are in place during the development, approval, and execution of compliance activity. Functional offices within TE/GE will provide resources to assist in the development of compliance strategies and data driven approaches and take appropriate actions as submissions move through the compliance strategy process.

Program Effectiveness:

Annual Review: The Director, CP&C reviews IRM 4.70.5 annually to ensure accuracy and promote consistent tax law administration.

Access the Portal directly, or through the TE/GE CP&C Submission Portal landing page, which can be accessed from the TE/GE Connect homepage.

II&SR includes IID analysts with various technical backgrounds from the TE/GE functional offices (EP and EO/GE) and Research analysts, economists, and statisticians.

IID analysts assess the submissions and develop proposals through the compliance strategy process, including:

The compliance strategy process establishes controls and procedures to focus resources on potential non-compliance.

The Portal uses Power Apps, Power Automate and SharePoint to aid in documenting the compliance strategy process through the life cycle of a submission.

All TE/GE employees have access to make a submission into the Portal. Full access to the Portal is limited to CP&C employees who are developing proposals, building cases, stocking the virtual shelf, monitoring implementation of compliance activities and those requiring oversight.

The Portal contains a section to allow for the KM team and IID analysts to jointly score issue submissions.

The chart below describes all the Portal sections:

The main goal of the compliance strategy process is to identify areas of potential non-compliance as soon as possible. All employees are encouraged to make submissions when non-compliance may be present in a broader population.

Non-compliance can be identified by:

The submitter must:

The submitter may include attachments to the submission.

The Portal automatically generates email notifications at various stages of the compliance strategy process in relation to issue submission.

The Portal is NOT for examination tips, asking questions or requesting IRM or form changes.

The IID manager and analysts review submissions monthly. As a group they:

IID group collaborates with KM team to score the submission to determine if it is truly a compliance issue (e.g., a suggestion to change a form or process is not a compliance issue).

IID manager monitors work portfolios of IID analysts and, as appropriate and based on the joint score, assigns the submission to the appropriate Issue ID analyst.

IID analyst reviews the assigned submission and sets the status to In Development within the Portal. Specifically, the IID analyst:

IID analyst assembles the ID team, including a researcher and a KM team member, to begin development of the proposal.

IID analyst performs initial research (What is the law? Is the proposal a viable violation?) based on scoring priorities. The IID analyst documents their findings within the Portal, including any delays in assembling the ID team or developing a proposal.

IID analyst and the ID team refine the focus and scope to compile an initial recommendation for discussion by the Board, as appropriate. If the open discussion by the Board doesn’t take place, the ID team continues development (see IRM 4.70.5.2.9, Proposal Development). The IID analyst:

IID analyst documents all meetings and feedback within the Portal.

IID analyst presents the initial recommendation to the Board for open discussion.

All meetings and feedback are documented within the Portal.

IID analyst continues to expand the ID team as necessary adding new members to the Portal.

IID analyst provides initial input to the Development Plan and Workstream(s) sections of the Portal.

IID analyst determines if other Business Units are doing similar work (e.g., LB&I campaign or SB/SE campus program). If so, the IID analyst contacts the appropriate point of contact to avoid duplication of work, maintain consistency across IRS, and to identify any differences between their efforts and those of TE/GE. The information gathered should include who is performing the work (e.g., field - general or specialists, campus, etc.) how their population was identified, what their parameters and thresholds are, available training and letters, and any preliminary or final results of their work.

IID analyst uses a pro-forma PowerPoint to build the draft Board presentation, which may be presented to the Exam Director to gain their insight. The presentation may include draft language for letters or IDRs specific to the proposed compliance strategy (i.e., not the entire letter).

The IID analyst delivers a summary of the proposal to the appropriate Exam Director. The synopsis is based on information contained in the Portal which includes:

The ID analyst updates the Portal to:

After the Exam Director briefing, the IID analyst continues strategy development by working through the other Portal sections and finalizing the PowerPoint slides for presentation to the Board.

The IID analyst identifies a population and must either prioritize the case list or, if no priority order can be identified, use a sample from the list to meet WP needs. IID and P&M coordinate with the WPA to recommend a suitable number of cases to work.

The IID analyst finalizes the PowerPoint for the Board presentation. IID analyst coordinates with P&M analysts (e.g., WPA, VSM, PMC) and includes Exam Director’s input to make a preliminary determination based on priority of compliance strategy and proposed placement within the Workplan.

CP&C Director reviews the proposal before it is presented to the Board.

The IID analyst posts the final PowerPoint proposal presentation to the Board’s SharePoint site (restricted access). Other supporting documents are stored within the Portal, which the Board members have access to.

Board members review the PowerPoint and other proposal documents prior to the monthly Board meeting.

The IID analyst or other ID team member(s) summarize the team’s proposal(s) at the next monthly Board meeting.

Board members ask questions during the presentation and may request additional information be provided at a future meeting.

The proposal becomes a compliance strategy only when the Board approves it.

Based on the approved workstream(s), the ID team works with the functional champion, if assigned, and KM team to identify any relevant tools, training, documents and other information that is available or needs to be developed.

The ID team prepares the compliance strategy package which includes:

The IID analyst uploads the compliance strategy package documents to the Portal and adds a new Plan Details record with handoff date. This notifies P&M that the compliance strategy treatment plan(s) is (are) ready for implementation. The VSM updates the Portal to input the stocking report and C&CA is notified that case building can begin.

The PMC is responsible for project management of the implementation phase of the compliance strategy process, which includes post-strategy monitoring and periodic updates to the Board.

The Board considers the progress of all implemented compliance strategies. Specifically, they:

Research supports the IID analyst during the compliance strategy process and develops, maintains, and evaluates data-driven compliance efforts for compliance activity development.